March 2019 Quarterly Results 2 | KPMG | FIPS Quarterly Results March 2019 Overview
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Financial Institutions Performance Survey FIPS March 2019 Quarterly Results 2 | KPMG | FIPS Quarterly Results March 2019 Overview Phase Two of the Review insurance cover per depositor, per We have little to no doubt that this of the Reserve Bank Act insured bank, is USD$250,0007; and process will be worked through in the EU, deposits are protected up as part of the finer details of the On 24 June 2019, the New Zealand to €100,0008. programme; however, since such Government announced some in- schemes are normally funded by the However, the New Zealand Treasury principle decisions as part of Phase banks themselves through levies, we claims that “It would also be broadly Two of the Review of the Reserve will watch deposit rates closely to consistent with international schemes Bank Act 1989 (the Review).1 see if these costs are passed on to in terms of the share of deposits depositors through reduced savings and depositors that would be fully The headline-grabbing feature of this interest rates, and possibly also under 2,3 protected (albeit relatively low in announcement was that Cabinet had the premise of the deposits being terms of the absolute dollar value of signed off an in-principle decision to ‘safer’ due to the protection. introduce a deposit protection regime protections)”9. in New Zealand as a result of the Another aspect to consider is whether While the process is still in its fairly work from the Review. The proposed this scheme will stay limited to early stages, with the finer details limits for the deposit protection are registered banks only. The Financial of the regime to be worked out, between $30,000 and $50,000. The Services Compensation Scheme in the seeing how the deposit protection Government claims these limits will UK and the Financial Claims Scheme regime works alongside the Open ”cover 90% of individual bank deposits in Australia covers banks, building Bank Resolution will be interesting. in New Zealand, which is similar to societies, and credit unions (all with Under the Open Bank Resolution international schemes”3. It is expected the same limits), while the proposed concept10, the bank enters the Open to cover 40% of total funds in bank regime in New Zealand is limited Bank Resolution stage when the bank deposits in New Zealand3. to banks only (similar to the USA becomes ‘unstable’ or ‘distressed’. and Europe). This process, when activated, would Cabinet had signed off an in- result in some deposits being frozen One final aspect to consider will principle decision to introduce while a statutory manager takes over be whether this deposit protection a deposit protection regime in the bank, and then this frozen money scheme will soften the Reserve Bank New Zealand. would be used to resolve the bank’s of New Zealand’s (RBNZ’s) view as to issues. The non-frozen money would the level of capital increase it pursues attract a government guarantee, and under its consultation. Finance deposits would remain open to access Minister, Grant Robertson, has raised This in-principle decision follows on for this non-frozen portion. this aspect as a possibility, but was from the recommendation from the equally quick to point out that it was a International Monetary Fund in their decision for the RBNZ to decide under report issued in April 2017 where The Open Bank Resolution also the New Zealand framework11. they commented that “To enhance its already includes the concept of [Open Bank Resolution framework’s] government guarantee over non- One other, less prominent, credibility and strengthen the financial frozen funds. feature of the in-principle decision safety net, the introduction of deposit announcement was Cabinet deciding insurance would be the best option”4. that the next consultation in Phase Two of the Review will focus on whether In comparison to the limits employed The difference between this concept the RBNZ’s ‘supervisory regime is in some other large countries, the and the deposit protection regime is sufficiently strong’, including whether proposed limits in New Zealand seem that these deposit protection regimes it has the right enforcement tools, quite low. In Australia, deposits are require the bank to ‘fail’ in order for including whether current levels of protected for up to AUD$250,000 for the protection to be activated, while penalties are sufficient to ‘discourage each account holder at each bank5 the Open Bank Resolution, as the core certain behaviour’. (when the Australian Government of its purpose, steps in before the activates the scheme when a bank bank ‘fails’. The Open Bank Resolution As is being done with many other fails); in the UK, deposits are protected also already includes the concept of New Zealand regulatory regime up to £85,000 per eligible person, government guarantee over non- changes, the Government is or £170,000 for joint accounts, per frozen funds. observing how overseas countries, bank6; in the USA, the standard particularly Australia and the UK, create and implement these ideas. © 2019 KPMG, a New Zealand partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. FIPS Quarterly Results March 2019 | KPMG | 3 The announcement specifically The RBNZ received 164 responses Given the ‘volume of the responses’ noted Australia’s Bank Executive during the consultation period, as well received by the FMA and the RBNZ, Accountability Regime (BEAR) and as feedback through briefings with and the various other activities ongoing the UK’s Senior Managers Regime banks and other stakeholders. As a in the sector that will be consuming as two examples of frameworks to result of some of the feedback given regulatory resources (capital for banks, make the banks’ decision makers to the RBNZ as to the underlying similar conduct and culture reviews more accountable than before; as a analysis and advice underpinning for life insurers), it all went pretty result, the Government is considering the proposals, the RBNZ appointed quiet while the assessment of the adopting elements of these overseas three independent experts to review responses was carried out15. frameworks for New Zealand. the RBNZ’s capital proposals and On 24 June 2019, the FMA and associated analysis and advice. The Amongst other less prominent in- RBNZ announced that all banks three experts appointed are James principle decisions, one is to combine had committed to remove sales Cummings (senior lecturer in finance the regulatory regimes for banks incentives from frontline staff and at Macquarie University), Professor and non-bank deposit takers. While their managers16. As one of the Ross Levine (chair of banking and this outcome is unlikely to have a big most explicit expectations from the finance at the Haas School of impact for registered banks, it could FMA and RBNZ’s initial report on the Business, University of California, have a significant impact on the non- banking conduct and culture17, this Berkeley) and David Miles (Professor bank deposit-taker sector, depending area was one that banks placed a of Financial Economics at Imperial on the final details that are sorted out, great deal of attention on to ensure College London). Each expert will with some possibilities being additional this expectation was met, given it had produce a separate report that the cost and additional oversight. to be in place for performance years RBNZ intends to publicly issue, and beginning after 30 September 2019. Since we still have until early 2020 that the RBNZ will use as an “input While some banks retained sales before the final decisions are made into final decisions made in the incentives for some small groups and released, we have yet to see how capital review”14. of staff and financial metrics were much consultation with the sector, still in place in incentives for senior and the wider industry and public, will executives at most banks, these be had, if any, on these two matters. The RBNZ’s consultation on its roles were not as generally directly Either way, it looks as if a busy Capital Review closed on 17 May linked to sales staff or their direct schedule for the banks just became a 2019, wrapping up what must line management. The FMA and little busier than before. have been one of the RBNZ’s most controversial and widely discussed RBNZ have clearly stated that future What has been noticeable in the last consultations monitoring and controls will need to quarter has been the greater activity be in place around these remaining of the regulator, both in commenting financial metrics. on matters in the public domain (e.g. With an announcement to be made on Also, the announcement noted that the capital submission) and on acting the final capital changes in November the FMA and RBNZ were now moving on apparent breaches of the RBNZ 2019, and a transition period of ‘a “to monitoring the banks’ progress guidelines. A review of the banking number of years’ starting from April against the plans they’ve provided”17. sector related press releases for the 2020 before banks are required to With statements such as these, quarter has shown it to be a busy fully comply with any new rules, the while 1 April 2019 may have initially quarter across a range of issues. next few months may feel quite long felt like the end of a long process for for some of those most involved those involved, it is clear that these Capital and impacted. submissions were only the end of the After an extended consultation beginning of a new ‘norm’ of more period12, the RBNZ’s consultation Conduct and culture actively supervising regulators.